ADVANCING ANIMAL DISEASE TRACEABILITY

ROAD MAP FOR

THE EASTERN BAND OF CHEROKEE INDIANS 

A Three-Year Plan

Submitted by:

MIKE LAVOIE

NATURAL RESOURCES MANAGER

EASTERN BAND OF CHEROKEE INDIANS

P.O. BOX 1747, CHEROKEE, NC 28719

(828) 359-6113

Submitted to:

DR. LEW DODDS, DVM

AREA-VETERINARIAN-IN-CHARGE FOR WEST VIRGINIA AND

NORTH CAROLINA

VETERINARY SERVICES

ANIMAL AND PLANT HEALTH INSPECTION SERVICE

UNITED STATES DEPARTMENT OF AGRICULTURE

920 MAIN CAMPUS DR., SUITE 200

RALEIGH, NC 27606

919-855-7700

August 19, 2022
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Table of Contents

I. EXECUTIVE SUMMARY 3

II. CURRENT TRACEABILITY SITUATION 5

II.1Who are we? 5

II.2Where are we now? 6

II.3Strengths and Weaknesses 7

II.4Opportunities and Threats 7

II.5Inventory of existing infrastructure and suitability assessment 8

III. VISION AND MISSION CONTEXT FOR ADVANCING TRACEABILITY 8

III.1

Vision statement 8

III.2

Mission statement 8

IV. TRACEABILITY REQUIREMENTS 8

IV.1

Strategic goals 8

IV.2 

Programmatic goal(s) (Objectives) 8

IV.3

Animal disease traceability performance measures 9

IV.4

Data requirements 10

IV.5

Information technology plan 10

IV.6

Resource requirements 10

IV.7

Organizational needs 11

IV.7.1 Executive support 11

IV.7.2 Coordination and oversight procedures 11

IV.7.3 Policy 12

IV.7.4 Staffing 12

IV.7.5 Budget requirements 12

IV.7.6 Outreach 12

IV.7.6.1

Accredited veterinarians 12

IV.7.6.2

Livestock markets 12

IV.7.6.3

Industry as a whole 13

IV.8

Monitoring and reporting interstate movement activity 13
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V. TRACEABILITY IMPLEMENTATION 13

V.1Ranking of priorities for advancement 13

V.2 Implementation of objectives 14
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I. EXECUTIVE SUMMARY

The Eastern Band of Cherokee Indians (EBCI) is a Tribal nation located in Cherokee, 

North Carolina and is North Carolina’s only federally recognized Tribe. Historically, 

the EBCI was part of a larger Cherokee Nation. However, with the implementation of 

the Indian Removal Act of 1830 and the forcible relocation of over 16,000 Cherokee 

Indians in what became known as the ‘Trail of Tears’, the Cherokee Tribe became 

divided into the Cherokee Nation and the United Kituwah Band, located in Oklahoma. 

The Eastern Band, made up of those who remained and rebuilt within North Carolina’s 

Qualla Boundary, has a relationship with both the United States federal government 

and the state of North Carolina; however, the EBCI is self-governed and, as such, has 

its own government, laws, elections, and institutions. Terrain on the Tribal land varies 

from steep mountains to agriculture lowlands and contains approximately 200 miles 

of streams with 100 acre-miles of wetlands known for its trout fishery, species 

diversity, clear mountain streams, and scenic views. 

Within the last ten years, the Cherokee government has grown in size, capacity, and 

resources, an expansion that has driven parallel growth within key departments whose 

roles, responsibilities, and requirements, in some cases, overlap. This overlap has led 

to duplication of effort and unclear lines of authority between the Division of 

Agriculture and Natural Resources (DANR), the Division of Public Health and Human 

Services, and the Division of Police, as it concerns Animal Disease Traceability 

(ADT).

Currently, the DANR has management jurisdiction over all wildlife and agricultural 

resources for the Tribe, a change in policy that requires action plans to address new 

roles, responsibilities, and requirements to include the field of ADT. Presently, there 

are few resources dedicated to this effort. Achieving a workable Animal Disease 

Traceability system requires internal stakeholder input, cooperation with state and 

federal partners, and Tribal regulatory action, a process that is ongoing. 

EBCI goals for establishing an ADT program include:

● Securing USDA funding for ADT program implementation;

● Building out a fully-functioning ADT program that includes full 

participation from the various stakeholder offices both internal and 

external to the EBCI;

● Reducing risks related to the spread of disease by having the ability 

to quickly complete tracebacks to determine the origin of the 

diseased animals;

● Leveraging the best practices, lessons learned, and resources of state 

and federal partners conducting ADT;

● Codifying roles and responsibilities with regard to animal health 

responsibilities inside Tribal lands;

● Educating stakeholders and the public on the ADT mission and 

requirements
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To align the EBCI with federal, state, and Tribal ADT partners, the Division of 

Agriculture and Natural Resources will work within USDA’s 2010 ADT framework 

by ensuring program compliance through an emphasis on interstate animal movement, 

state and Tribal-level program administration, low-cost technology options, and 

transparency through the full Federal rulemaking process. Additionally, the EBCI will 

work with the state of North Carolina to share best practices, lessons learned, and 

resources with special emphasis on animal identification/tagging (i.e. Animal 

Identification Numbering tags or National Uniform Ear Tagging System), animal 

inspections, and record-keeping.

A joint, coordinated, and standardized ADT program will allow the Division of 

Agriculture and Natural Resources to effectively manage EBCI animal resources, 

trace interstate animal movement, mitigate risk through early detection of vulnerable 

animal populations, safeguard both animal and human health, coordinate ADT 

response, de-conflict overlapping levels of effort, and oversee program compliance. 

Compliance with an ADT program will facilitate interstate commerce for producers 

within the EBCI that wish to export animals to NC or any other state within the United 

States.

II. CURRENT TRACEABILITY SITUATION

II.1 Who are we?

Within in the EBCI, the Division of Agriculture and Natural Resources 

(DANR) is charged with developing, managing, implementing, and 

maintaining the ADT Roadmap.

Internal stakeholders within the EBCI include, but are not limited to:

● Office of the Attorney General 

● Division of Police (Natural Resource Enforcement Program and 

Animal Control Program)

● Division of Public Health and Human Services

● Division of Information Technology

● EBCI Fisheries & Wildlife Management

External constituents include but is not limited to:

● Producers

● Managers of exhibition venues such as fairs and zoos

● Non-producer participants, such as the captive cervid hunting 

facility in Graham County

● Private accredited veterinary practitioners

● North Carolina Department of Agriculture and Consumer Services 

(NCDA&CS)

● North Carolina Wildlife Resources Commission (NCWRC)

● U.S. Department of Agriculture, Animal and Plant Health 

Inspection Service, Veterinary Services (USDA APHIS VS)
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II.2 Where are we now?

Animal disease traceability - or understanding the movements of diseased 

and at-risk animals, where they have been, and when this movement occurs 

– is important to ensuring a rapid response when animal disease events take 

place. Although animal disease traceability does not prevent disease, an 

efficient and accurate traceability system reduces the number of animals and 

response time involved in a disease investigation, which, in turn, reduces 

the economic impact to owners and affected communities. 

Currently within the EBCI, limited operational resources exist for ADT. 

Burden-sharing on animal issues, specifically as it relates to inspections, 

exists between DANR, offices external to the EBCI (i.e. USDA APHIS, 

NCDA&CS), and offices within the EBCI, specifically, the Division of 

Police (Animal Control and Natural Resource Enforcement), as it concerns 

captive facilities (e.g. zoos) and private hunting pens. However, this 

coordination is based on immediate needs and personal relationships and 

not comprehensively mandated in EBCI regulation. Additionally, while 

piecemeal efforts to trace animals through inspections do exist to some 

extent at the EBCI program level, the extent of those efforts and the 

resources related to those efforts (e.g. tagging, record-keeping) are currently 

unknown. 

Tribal, state, and federal resources are required to establish, implement, and 

maintain an Animal Disease Traceability (ADT) system. Funding for ADT 

is not currently dedicated in the Tribe’s budget; however, federal grants 

provide some level of funding for select initiatives. No full-time staff is 

dedicated to ADT. 

Current categories of need include: Personnel, Programmatic, Financial, 

Educational, Technological, Informational, and Regulatory.

● Personnel resources include one to two dedicated staff to initially 

implement and manage program administration and field operations.

● Programmatic resources include building out key programs, most 

notably on animal identification, tagging, inspections, compliance, 

and outreach. 

● Financial resources include funds allocated from within the Tribe 

and from USDA for ADT implementation.

● Educational resources include training for Tribal ADT stakeholders 

(e.g. EBCI Tribal Council, EBCI programs with an ADT mission, 

producers) and outreach materials for the general public.

● Technological resources include a comprehensive, interoperable, 

and up-to-date Animal Information Database or records 

management system.
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● Informational resources include canvassing data from within the 

EBCI to determine the state, number, and type of animal resources 

and premises.

● Regulatory resources include updated EBCI codes, statutes, 

regulations, and policies that are coordinated between departments; 

that provide guidance, clarify roles, and outline authorities for all 

ADT stakeholders; and that are approved by Tribal leadership.

II.3 Strengths and Weaknesses

Strengths of the current ADT landscape include:

● Constructive, ongoing relationships with key stakeholders within 

the EBCI (i.e. Animal Control, Public Health, Legal, Natural 

Resource Enforcement, Fish and Wildlife) and external constituents 

to include USDA APHIS and NCDA&CS

● Prioritization of ADT program within the DANR 

● Opportunities for external resourcing and resource-sharing with 

external constituents to include USDA

● Completion of EBCI DANR ADT Implementation Guide to focus 

future ADT program development initiatives

● Development of draft ADT administrative regulations to be legally 

executed under the Cherokee Code Administrative Procedures Act 

when program staff capacity needs are met

● Completion of permitting and regulatory forms as defined by ADT 

Implementation Guide

Weaknesses include:

● Lack of funds dedicated to ADT program development and 

implementation

● Lack of examples of successful ADT implementation across Tribes

● No full-time staff dedicated to ADT

● Varied and uncoordinated levels of effort for ADT across the 

different sections of the EBCI 

● Unclear lines of authority originating from outdated codes, 

ordinances, statutes, and regulations related to animal resources

● DANR is in initial phases of developing a unified record-keeping 

system and technology offerings for digital records management and 

databasing

● Limited canvassing data available to provide accurate inventories of 

producers and animal premises

● Limited historical data on previous USDA-funded ADT work on 

cattle tagging and vaccinations

● Limited educational or outreach materials for public awareness

II.4 Opportunities and Threats

Without a comprehensive ADT plan with supporting staff capacity, the 

EBCI is at risk for animal-to-human and animal-to-animal disease 
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transmission such as Tuberculosis, Brucellosis, and Chronic Wasting 

Disease (CWD) and other diseases as of yet unknown. In addition to 

safeguarding human and animal populations, this plan will allow the EBCI 

to collect information to better understand animal population centers, 

producer and premise information, disease risk factors, and community 

concerns, among many others. It will also provide the DANR an opportunity 

to connect with other internal stakeholders and external constituents on 

ways to improve coordination especially as it relates to inspections, tagging, 

record-keeping, information management and databasing, and rapid 

response. Without immediate attention for ADT, the EBCI is at risk for 

intra-Tribal and interstate disease transmission.

II.5 Inventory of existing infrastructure and suitability assessment

Currently, the EBCI has limited resources dedicated to ADT. The Natural 

Resources Manager within the DANR is assigned high-priority tasks related 

to ADT but only as additional duties. Within the Division of Police, the 

Animal Control department has conducted inspections and performed other 

ADT functions. However, both offices’ efforts have taken place without the 

structure, accountability, and standardization of a unified framework, as 

outlined in the Code of Federal Regulations (CFR) Title 9 Part 86, Animal 

Disease Traceability. 

 

III. VISION AND MISSION CONTEXT FOR ADVANCING TRACEABILITY

III.1 Vision Statement

An EBCI Animal Disease Traceability program that protects human, 

livestock and wildlife health and animal-related economic resources 

through the identification, prevention, and mitigation of animal diseases 

introduced onto EBCI lands. 

 

III.2 Mission Statement

The mission of the Division of Agriculture and Natural Resources within 

the Eastern Band of Cherokee Indians is to manage, enhance, and protect 

agricultural and natural resources for the present-day Cherokee community 

and future generations. 

IV. TRACEABILITY REQUIREMENTS

IV.1 Strategic goal(s)

To develop and implement an EBCI-wide infrastructure for advancing 

Animal Disease Traceability that is compatible with Tribal, state, and 

USDA standards.

IV.2 Programmatic Goals (Objectives):

Objective 1: Secure funding for ADT implementation.

Objective 2: Train dedicated staff on full scope of ADT program.
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Objective 3: Build out and disseminate programs for Animal Identification, 

Tagging, Inspections and Compliance.

Objective 4: Assess future ADT-related financial needs.

Objective 5: Develop a responsive educational outreach program.

Objective 6: Maintain paper-based or electronic animal information through 

technological solutions by using existing databases (e.g., NCDA's Animal 

Health Database) and/or developing an in-house capability.

Objective 7: Regularly update information on the number of premises to 

include farms, exhibition venues, fish hatcheries, and non-producer 

participants.

Objective 8: Update EBCI codes, ordinances, and regulations to define key 

terms, clarify roles, establish clear lines of authority, and outline 

responsibilities related to ADT, specifically in Chapters 19 and 113 of the 

Code of Ordinances.

IV.3 Animal disease traceability performance measures 

The EBCI does not currently have a unified ADT program. As such, there 

is no opportunity to measure progress. Once this program is up and running, 

the EBCI will formulate performance metrics to determine progress. These 

metrics will take into account performance measures outlined in the 

FY2011 Animal Disease Traceability Cooperative Agreement, namely: 

1. Time required for the State or Tribe of destination to notify the State or 

Tribe in which the reference animals were officially identified.

2. Time required for the State or Tribe where the official animal number 

(i.e., official ear tag) was issued to validate the application and/or issuance 

of the reference animal numbers for which they were notified (in 

Performance Standard 1). This can be accomplished using distribution 

records that contain contact information for the business or operation to 

which the numbers were issued. 

3. Time required for the State or Tribe of destination to notify the State or 

Tribe from which the reference animals were shipped. Increasing 

electronically searchable data from the Interstate Certificates of Veterinary 

Inspection (ICVI) as well as the use of electronic ICVIs will make achieving 

this performance standard easier. 

4. Time required for the State or Tribe of origin to validate the movement 

of the reference animals for which they were notified (in Performance 
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Standard 3) from the State or Tribe of origin to the State or Tribe of 

destination. This can be accomplished using required ICVI information, 

which includes the location where the inspection by an accredited 

veterinarian takes place and the location to which the animals are moved 

interstate. A movement permit or other document may be used when the 

equivalent information reflecting the shipped from location and location of 

destination can be determined. 

5. Compliance with ADT identification requirements of producers located 

within EBCI boundaries.

IV.4 Data requirements

The amount and quality of data collected on animal movement and disease 

within the EBCI is unknown. Additionally, there is no centralized data 

collection point or data standards in place. General data management does 

occur within the EBCI through the Division of Information Technology; 

however, to date, ADT information has not been maintained on currently 

accessible servers. 

When funding is secured, the EBCI will develop or adopt an existing data 

management plan that is coordinated with the Division of Information 

Technology and is in alignment with 9 CFR, the Animal Identification 

Management System (AIMS), the National Uniform Ear Tagging System 

(NUES), the Animal Identification Number (AIN) system, and the Interstate 

Certificate of Veterinary Inspection (ICVI) process as outlined in the 

Animal Disease Traceability Comprehensive Report and Implementation 

Plan. 

Traceability data will be shared with other State/Tribes/Territories/USDA 

upon request and only when approved by the EBCI Department of 

Agriculture and Natural Resources. 

IV.5 Information Technology plan

No current Information Technology (IT) plan exists for ADT. However, 

DANR will develop an ADT IT plan in coordination with:

● EBCI Division of Information Technology

● USDA’s premise identification systems through a federally owned but 

locally hosted data center

● USDA’s Animal Identification Management System (AIMS) 

● Animal Trace Processing System (ATPS), and

● Animal Health Information Repository

Other areas of IT coordination include using North Carolina’s Animal 

Health Program (AHP) database or SCS Core One. The AHP database is 

housed on a Sequel server platform at the NCDA & CS and is part of the 
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Multi-Hazard Threat Database (MHTD), which serves the entire 

Department in emergency response situations. 

IV.6 Resource requirements

Building out an ADT program from the ground up will require robust, 

comprehensive resources. Described in detail above, these resources 

include Personnel, Programmatic, Financial, Educational, Technological, 

Informational, and Regulatory needs, specifically.

● Investigating resource-sharing and funding opportunities with 

USDA on EBCI ADT program implementation.

● Coordinating with USDA, NCDA&CS, and Tribal stakeholders to 

build out key programs, most notably an Animal Identification and 

Tagging program and an Animal Inspections and Compliance 

program.

● Allocating funds from within the Tribe and from USDA for ADT 

implementation.

● Creating educational resources such as training materials for Tribal 

ADT stakeholders (e.g., EBCI Tribal Council, EBCI programs with 

an ADT mission, producers) and outreach materials for the public.

● Implementing IT solutions that are comprehensive, interoperable, 

and up to date.

● Collecting canvassing data from within the EBCI to determine the 

state number, and type of animal resources and premises.

● Updating EBCI statutes, regulations, and policies that are 

coordinated between departments; that provide guidance, clarify 

roles, and outline authorities for all ADT stakeholders; and that are 

approved by Tribal leadership.

IV.7 Organizational needs

The standing up of the DANR within the EBCI has necessitated new roles 

and responsibilities regarding animal resources. Currently, DANR is wellpositioned to house the ADT program and associated EBCI codes, 

ordinances, and regulations are being updated to reflect this reality. 

However, DANR recognizes that the success of this program relies on full 

partnerships with programs within the EBCI that have an ADT mission to 

include the Division of Police, the Division of Public Health and Human 

Services, and the Office of the Attorney General and external stakeholders, 

most notably USDA and NCDA&CS. Leveraging the full support and 

regular participation of these stakeholders is critical to ensuring mission 

success.

IV.7.1 Executive support

The ADT program has the full support of the Division of Agriculture 

and Natural Resources and the Office of the Principal Chief. 

IV.7.2 Coordination and oversight procedures
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The ADT Advisory Committee comprises those offices listed in 

Section II.1 and includes offices with animal resource 

responsibilities within the EBCI and external constituents with an 

ADT mission. Regular and as-needed meetings will occur to review 

roles and responsibilities related to ADT as well as to discuss 

mission requirements, performance metrics, measures of 

effectiveness, and progress in key areas to include emergency 

preparedness and rapid response. As the program manager for the 

ADT program, DANR will solely handle routine mission 

responsibilities, coordination with key stakeholders, and general 

oversight.

IV.7.3 Policy

The EBCI has updated its code related to animal health resources, 

specifically Chapters 19 and 113 of the EBCI Code of Ordinances 

to reflect the authority of the DANR for all animal health issues to 

include ADT. Administrative regulations pursuant to Chapter 150 

(Administrative Procedures Act) have been drafted by DANR but 

remain unexecuted due to the lack of capacity to ensure compliance 

is met. The ADT Roadmap must be consistent with the EBCI Code 

of Ordinances and associated administrative regulations. 

IV.7.4 Staffing

Current staff organization within the DANR is not poised to address 

the requirements of the ADT plan. With input from external 

constituents and ADT specialists, the DANR will consider the full 

range of human resource options to include USDA grant assistance, 

cross-leveling existing or future staff within the DANR and hiring 

full-time employees for ADT plan implementation. DANR has 

sought EBCI resources for Fiscal Year 2023 to hire a new 

Regulatory Supervisor FTE. This position, if fully funded, will add 

capacity to meet the critical components of ADT implementation 

guidance for the EBCI. Additional staff resources will still be 

needed for the EBCI ADT program to be fully effective. 

IV.7.5 Budget requirements

ADT currently lacks adequate funding for effective program 

implementation. In coordination with the EBCI Tribal Council, the 

DANR will outline funding requirements and cost-sharing options 

to include USDA grant requests, specifically the USDA ADT 

Cooperative Agreement and requests to share resources with 

NCDA&CS. 

IV.7.6 Outreach 

One of the main objectives of the EBCI Animal Traceability 

Program is to conduct outreach activities to producers, accredited 
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veterinarians, livestock markets, harvest facilities and other industry 

shareholders. 

IV.7.6.1. Accredited veterinarians

Accredited veterinarians are important in animal 

identification efforts; however, the EBCI has no inhouse veterinarians. As such, to support the ADT 

mission, the DANR will partner with external state 

and private constituents to conduct inspections and 

produce veterinary certificates on to and out from 

Tribal lands. Once the program is up and running, the 

requirement for inspections will be reduced to 

incoming animals and disease outbreaks, greatly 

reducing the need for veterinarians.

IV.7.6.2. Livestock markets

The EBCI does not maintain livestock markets. 

IV.7.6.3 Industry as a whole

Outreach to industry and other stakeholders within 

the EBCI is critical to this plan and will occur in 

several communication forums to include ADT 

Advisory Committee meetings. An outreach plan to 

inform the public will be part of the ADT program. 

IV.8. Monitoring and reporting interstate movement activity 

Animal movements, the numbers of shipments, and the number of Interstate 

Certificates of Veterinary Inspection (ICVIs) for both imports and exports 

are not currently being monitored or recorded. When monitoring and 

movement data collection does occur, it will comply with 9 CFR 86. 

Quarterly reports are mandated by USDA and will include: 

● Number of ICVIs and other interstate movement documents 

created within the State/Tribe/Territory on a year-to-date basis for 

move-out animals.

● Number of ICVIs and other interstate movement documents 

received for move-in animals.

● Number of animals by species and class for move-in events 

associated with ICVIs and other interstate movement documents, 

indicating the number of animals officially identified and the 

number not officially identified.

● Number of animals by species and class for move-out events 

associated with ICVIs and other interstate movement documents, 

indicating the number of animals officially identified and the 

number not officially identified.

● Volume of distribution for each official numbering system/device 

issued by the State/Tribe/Territory and/or AVIC office, including 

backtags by market or processing (slaughter) facility.
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V. TRACEABILITY IMPLEMENTATION

V.1 Ranking of priorities for advancement

1. Secure approval of vetted and reviewed ADT Roadmap; publish 

Roadmap.

2. Secure approval of updated Code of Ordinances to reflect ADT 

Roadmap responsibilities.

3. Develop and secure approval for ADT implementation.

4. Secure USDA-funding for ADT implementation.

5. Hire new staff or train existing staff on ADT implementation.

6. Build out programs for Animal Identification, Inspections, Tagging, 

Compliance, Canvassing, Record-keeping and Databasing, 

Information Sharing, Performance Measures, Rapid Response, and 

Outreach.

7. Capture and track traceability data from ICVIs.

8. Engage in public outreach and education.

V.2 Implementation of objectives

Objective 1: Secure USDA funding for ADT implementation through the 

Veterinary Services Grants and Agreements Program, part of the Animal 

and Plant Health Inspection Service (APHIS). Investigate other funding 

opportunities to include internal to the Tribe.

Objective 2: Train ADT program manager and ADT staff on ADT 

architecture, program requirements to include record-keeping, data 

management and Information Technology, duties, key points of contact 

both internal and external to the Tribe, reporting requirements, legal 

obligations, and other aspects of the program.

Objective 3: Build out programs for Animal Identification, Tagging, 

Inspections and Compliance. Programs will include purpose, program 

objectives, key offices and contact information, program requirements, 

forms, and implementation guidance. Upon review and publication, 

disseminate.

Objective 4: Assess future financial needs by:

● Requesting funds for ADT implementation through USDA, 

NCDA&CS, and EBCI Tribal Council

● Exploring partnership opportunities 

Objective 5: Develop an educational outreach program that includes 

physical pamphlets and posters, site-specific informational visits, town hall 

meetings, and social media awareness campaign.
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Objective 6: Maintain paper-based or electronic animal information through 

technological solutions by using existing databases (E.g. NCDA's Animal 

Health Database) and/or developing an in-house capability.

Objective 7: Gather information on the number of premises to include 

farms, exhibition venues, and non-producer participants by canvassing 

within the EBCI.

Objective 8: Update EBCI codes, ordinances, and regulations in order to 

define key terms, clarify roles, establish clear lines of authority, and outline 

responsibilities related to ADT, specifically in Chapters 19 and 113 of the 

EBCI Code of Ordinances. Coordination should occur with NCDA&CS, 

USDA APHIS, and key stakeholders within EBCI to include the Division 

of Police (Animal Control and Natural Resources Enforcement), the 

Division of Public Health and Human Services, Fish and Wildlife 

Management, and the Office of the Attorney General.